Jacob Baxter v. Danny R. Cheadle and Village of Palestine, Illinois

Summary

The United States District Court for the Southern District of Illinois denies Jacob Baxter’s motion for reconsideration of the dismissal of his claims against Danny R. Cheadle and the Village of Palestine, Illinois. The court holds that Baxter identified no newly discovered evidence, intervening change in law, or manifest error warranting relief under Federal Rule of Civil Procedure 59(e). The court also denies Baxter’s request to amend because the pleading deadline had passed and amendment would not cure his failure to identify clearly established law defeating Cheadle’s qualified-immunity defense.

Holdings

1. The court denied reconsideration because Baxter identified no newly discovered material evidence, intervening change in controlling law, or manifest error of law or fact.
2. The court held that qualified immunity may be resolved on a Rule 12(b)(6) motion when the plaintiff states a constitutional claim but fails as a matter of law to identify clearly established law that would have put a reasonable official on notice that the conduct was unconstitutional.
3. The court declined to consider Baxter's argument that Cheadle lacked discretionary authority because Baxter could and should have raised it in response to the motion to dismiss.
4. The court denied leave to amend because the amendment deadline had passed and amendment would not cure Baxter's failure to identify clearly established law supporting his qualified-immunity claim.

Questions Presented

1. Whether Baxter established newly discovered evidence, an intervening change in controlling law, or a manifest error of law or fact warranting relief under Rule 59(e).
2. Whether the court improperly resolved qualified immunity at the pleading stage.
3. Whether Baxter could raise for the first time on reconsideration an argument that Cheadle lacked discretionary authority to terminate him.
4. Whether Baxter should be permitted to amend his complaint after the dismissal.

Disposition

other